CV Check Ltd Modern Slavery Policy April 2022

CV Check Ltd
Modern Slavery Policy
April 2022

Table of Contents

Contents
Table of Contents ....................................................................................................................2
Introduction ..............................................................................................................................3
   Preamble ..............................................................................................................................3
   Purpose of Policy .................................................................................................................3
   Policy ...................................................................................................................................3
   Scope ...................................................................................................................................3
Roles & Responsibilities ..........................................................................................................4
   Chief Operating Officer (COO) ............................................................................................. 4
   Finance Manager .................................................................................................................4
   CVCheck Executive Leadership Team (ELT) ...................................................................... 4
   Employees, Contractors, Temporary staff, and Consultants................................................ 4
Procedure ................................................................................................................................4
   New Supplier ........................................................................................................................4
   Existing Suppliers ................................................................................................................4
   Assessment Criteria .............................................................................................................4
   Adverse Findings .................................................................................................................5
Definitions / Artefacts ...............................................................................................................5
Review and Publication of this Policy ...................................................................................... 5
Document Control ....................................................................................................................5
      Version Control .................................................................................................................5

Introduction
Preamble
On 1st January 2019, the Commonwealth Modern Slavery Act 2018 (the Modern Slavery Act) came into
effect. It established, for certain organisations, reporting requirements to support the Australian business
community to identify and address their modern slavery risks, and to maintain responsible and
transparent supply chains.
While not an organisation that has obligations under the Modern Slavery Act 2018 (Cth) (“the Act”),
CV Check Ltd (“CV1”) none-the-less recognises an ethical obligation to consider the intent of this
legislation.
CV1 therefore seeks to limit the risk of modern slavery occurring within our supply chain. CV1 will take
commercially reasonable steps to ensure that we limit any risks with our goods or services suppliers.
Furthermore, as CV1 is not an organisation with statutory obligations to complete a Modern Slavery
Statement (“Statement”), any reporting will be internal only.

Purpose of Policy
This document defines CV1’s policy for limiting the risk of all forms of modern slavery from our supply
chain, and sets out whether, when, and how we will undertake any necessary verifications.
It includes CV1 Board reporting requirements.

Policy
The purpose of this Modern Slavery Policy is to ensure that CV1:
 •    complies with the intent of the Modern Slavery Act and relevant local and national laws;
 •    sources products and services in accordance with legal obligations and community expectations;
      and
 •    acts, and works with suppliers, to minimise the potential for modern slavery in the CV1 business
      and supply chain.
This policy should be read in conjunction with CV1’s following policies:
 •    Code of Conduct,
 •    Supplier Management Policy, and
 •    Whistleblower Policy.

Scope
This Policy applies to:
 •    employees, contractors, temporary staff, and consultants; and
 •    those third parties from whom CV1 purchases goods or services.
Whether CV1 should seek confirmation of agreement to our Supplier Code of Conduct will be based on
an assessment of the supplier. Only those considered “high” risk will be assessed via questionnaire.

Roles & Responsibilities
Chief Financial & Operating Officer (CFOO)
The CFOO has responsibility for ensuring compliance with this policy.
The CFOO will prepare a report, based on assessments made and confirmations sought – this will be
presented to the CV1 Board on a quarterly basis.

Finance Manager
The Finance manager has responsibility for:
 •    assessing suppliers as set out below, and
 •    seeking supplier confirmation of agreement to our Supplier Code of Conduct.
The Finance manager will report findings to the CFOO.

CV Check Ltd Executive Leadership Team (ELT)
The ELT have responsibilities as set out below – see Review and Publication of this Policy.

Employees, Contractors, Temporary staff, and Consultants
All personnel are to be aware of this policy, and other related policies, and consistent with CV1’s
Whistleblower Policy, understand their obligations to report anything they believe breaches any policy.

Procedure
New Supplier
Together with the CV Check Ltd Legal Counsel, the Finance Manager will assess new suppliers. Based
on that assessment, should the supplier be considered “high risk”, the new supplier will be asked to
complete the Code of Conduct questionnaire.

Existing Suppliers
A periodic review will be undertaken of existing suppliers, any re-assessed as “high risk” will trigger CV1
to request the supplier to complete the Code of Conduct questionnaire.

Assessment Criteria
Assessments will consider:
 •    The size and nature of the supplier’s business (i.e. we would not need to seek an assessment of a
      large public or well-known company – their reputational damage would be a deterrent for such an
      organisation);
 •    The size and nature of the business we have with the supplier (i.e. for some suppliers, we only
      conduct a single check – it would be commercially unreasonable to do further checks);
 •    Geographies in which the supplier operates; and
 •    The supplier’s industry – e.g. professional organisations vs labour-intensive, unskilled industries.
Other considerations may be included as needed, or as directed by the ELT.

Adverse Findings
Should an adverse finding be made for a supplier, CV1 will:
 •       First seek to have the supplier remedy the finding, and
 •       Should the supplier be unable or unwilling to remedy the finding, CV1 will endeavour, where
         possible, to remove that supplier from our Supply Chain.

Definitions / Artefacts
 Supplier Code          CV1 requests our Suppliers complete a “Supplier Vendor Form”. The
 of Conduct             “Supplier Vendor Form” has an embedded Supplier Code of Conduct, and we
                        request our Suppliers to complete and sign this document acknowledging that
                        they will conduct business in an honest, transparent, and ethical manner.

Review and Publication of this Policy
The CV Check Ltd Executive Leadership Team (ELT), with guidance from the CV Check Ltd in-house
Legal Counsel will review this Policy annually to confirm that it represents an ethical response to the
Modern Slavery Act 2018 (Cth). The ELT may, in its discretion, adjust or exclude a specific
requirement of this Policy from time to time, either generally or on a case-by-case basis. This Policy
may be amended, ceased, or replaced, by the ELT.

Document Control
 Policy Owner / Approver           Craig Sharp

 Title                             General Counsel

 Next Review                       November 2022

Version Control

 Version Date               Author               Title             Notes

 01.0         7/10/2021     Michael Sheard       Bid Coordinator   Creation

 01.2         4/11/2021     Michael Sheard       Bid Coordinator   Responsibilities clarified.

 01.3         27/04/2022 Craig Sharp             General Counsel   Approved by Board